Privacy Policy

Effective date: March 1, 2021


Qmulate Capital (“Qmulate”, “Company”, “we”, or “us”) respects your privacy and is committed to protecting it through compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you use (the “site”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. Use of the site is governed by the laws of the United States.

When you provide us with information, you acknowledge that the information will be stored and processed on servers located in the United States. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our site.

By downloading or using this site, you agree to this privacy policy. This policy may change from time to time. Your continued use of this site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Using our services

You may invest using Qmulate’s services by clicking on the “Invest Now” or “Invest with Us” buttons or by visiting the “invest” page. That link will take you to our advisor page provided by Robust Wealth and Apex Clearing Corp. The investment relationship, and the information you provide through that link, are not governed by these Terms of Use or this site’s Privacy Policy. They are instead governed by our Client Engagement Agreement, Privacy Policy Statement, Robust Wealth and Apex Clearing Corp disclosures and proprietary documents, all of which will be presented to you when you sign up.

2. Minors under the age of 18

Our site is not intended for minors under 18 years of age. No one under age 18 may provide any personal information to or on the site. We do not knowingly collect personal information from minors under 18.

If you are under 18, do not use or provide any information on this site or on or through any of its features, register on the site, make any purchases through the site, use any of the interactive or public comment features of this site, if any, or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use.

If we learn we have collected or received personal information from a minor under 18, we will delete that information. If you believe we might have any information from or about a minor under 18, please contact support.

3. Privacy and copyright protection

Qmulate's privacy policies explain how we treat your personal data and protect your privacy when you use our Services. By using our Services, you agree that Qmulate can use such data in accordance with our privacy policies.

We respond to notices of alleged copyright infringement and terminate accounts of repeat infringers according to the process set out in the U.S. Digital Millennium Copyright Act.

We provide information to help copyright holders manage their intellectual property online. If you think somebody is violating your copyrights and want to notify us, you can find information about submitting notices and Qmulate's policy about responding to notices in our Help Center.

4. Information we collect about you and how we collect it

We may collect several types of information from and about users of our site, including information:

• By which you or others may be personally identified, such as name, postal address, email address, and phone number (“personal information”).

• That helps us connect with one another, such as meeting location and anything else you want to share.

• About your internet connection, the equipment you use to access our site and usage details.

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and device information collected through cookies, and other tracking technologies.

The firm collects personal information about customers from the following sources:

• Information customers provide to complete their financial plan or investment recommendation;

• Information customers provide in engagement agreements and other documents completed in connection with the opening and maintenance of an account;

• Information customers provide verbally; and

• Information received from service providers, such as custodians, about customers’ transactions.

The firm does not disclose non-public personal information about our customers to anyone, except in the following circumstances:

• When required to provide services our customers have requested;

• When our customers have specifically authorized us to do so;

• When required during the course of a firm assessment (i.e., independent audit); or

• When permitted or required by law (i.e., periodic regulatory examination).

Within the firm, access to customer information is restricted to personnel that need to know that information. All access persons and service providers understand that everything handled in firm offices are confidential and they are instructed not to discuss customer information with someone else that may request information about an account unless they are specifically authorized in writing by the customer to do so. This includes providing information about a spouse’s IRA or to children about their parents’ accounts, etc.

To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to protect the privacy of customer information.

The firm will provide our customers with its privacy policy on an annual basis per federal law and at any time, in advance, if firm privacy policies are expected to change.

A. Information you provide to us

The information we collect on or through our site may include:

• Information that you provide by using the scheduling functionality of the site. We may also ask you for information when you fill out a survey or when you report a problem with our site.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your search queries on the site.

B. Automatic information collection

When you download, access, and use the site, we may automatically collect certain details of your access to and use of the site, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the site.

We use the following technologies to collect this information: Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our site.

C. How we use your information

We may use information that we collect about you or that you provide to us, including any personal information:

• To present our site and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our site or any products or services we offer or provide through it.

• To allow you to participate in interactive features on our site.

• To market our products or services to you.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

D. Disclosure of your information

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent. We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of use and other agreements.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Qmulate, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5. Accessing and correcting your personal information

You may send us an e-mail to support to correct or delete any personal information that you have provided to us through this site. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

6. Choices about how we use and disclose your information

If you do not wish to have us use your email address to promote our own products or services, you may opt-out by contacting support. You may also unsubscribe by using the link in any email message you receive. We may, however, still use your email address to contact you regarding your use of our service

7. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The transmission of information via the internet is not completely secure. While we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the site.

8. California Privacy Rights

We do not comply with requests under California Civil Code Section § 1798.83 because we do not disclosure your personal information to third parties for their direct marketing purposes. We also do not respond to Do Not Track browser signals.

Contact us

Please send all feedback, comments, requests for technical support, notices of copyright infringement and other communications relating to the site to support.